CBSA Assessment and Revenue Management | C.H. Robinson (2024)

Q: How will I set up users and delegate authority to my broker in the CARM Client Portal?

The CARM Client Portal will provide two levels of administrative access:

  • Business Account Manager (BAM) – primary
  • Program Account Manager (PAM) – secondary admin

Business Account Managers have the responsibility of approving and setting up employee access to the business and program accounts. Before access to the business or program account is granted, each employee must first set up their own personal user account in the portal and request access to be added to the business account.

With the CARM Client Portal, the login has changed from broker to importer RM extension.

Both BAM and PAM users have the administrative authority to manage business relationships and add brokers and consultants.

Note that delegation within the CARM Client Portal does not negate the need to maintain a General Agency Agreement with your customs broker.

Q: Will the CBSA CARM transition lead to a new commercial accounting declaration process?

The process for accounting for imported goods into Canada will change when CARM introduces the Commercial Accounting Declaration (CAD) with Release 2. The CAD is a digital document that will replace the existing Canada Customs Coding Form (B3) and Canada Customs Adjustment Request (B2) documents.

This shift will adopt a World Customs Organization (WCO) compliant data model and will help with version control as changes occur to better retain an accurate historical record. Version management in the CAD creates a single accounting declaration of record, eliminating the requirement to account for submissions and changes on separate document types.

Q: How will I handle corrections, adjustments, rulings, and drawbacks with CBSA CARM?

Corrections may be made up until the payment due date, after which time any changes or corrections made to the CAD will be considered as adjustments.

Mass adjustments can be used to bundle two (2) or more changes to information.

In Release 1 of CARM scheduled for May 2021, the CBSA will introduce a case management functionality for rulings. Rulings can be applied for online.

Details on filing a CAD for drawback purposes are limited at this time. It’s understood that a drawback will be considered as a mass adjustment. Further details and clarity on drawbacks will be available soon.

Q: What can I expect for CBSA billing and payments?

At Release 1, the CBSA will enable electronic payment options to include:

  • EDI transmission
  • Pre-authorized debit (PAD)
  • Debit/credit card payments, up to the defined limits
  • Cheque or money order made out to the Receiver General of Canada
  • Cash

At Release 2, CARM billing cycle changes come into effect. The introduction of new billing cycles and an alignment of payment due dates will address current complexities concerning debt management for businesses and ease the administrative burden of managing this process.

The following billing cycles will be affected by CARM:

  • High value shipments (HVS)/Low value shipments (LVS)
  • LVS goods released in the regular commercial stream will follow the standard HVS billing cycle
  • Courier low value shipments (CLVS)
  • Continuous transmission commodities (CTC)
  • Customs self-assessment (CSA) program

Also upon Release 2, financial statements will be issued via the CARM Client Portal and to EDI certified account holders and customs brokers via EDI in XML format.

Q: How will I and my broker receive daily notices with CARM?

The customs broker and importer will receive daily notices via the CARM Client Portal and/or EDI for the transactions they have accounted for on behalf of their clients. The customs broker can view their client’s transaction information in the portal only if delegated to do so by their client.

Q: How will I receive CBSA statements of account?

Starting with Release 2 of CARM, statements of account will be issued to all trade chain partners that have incurred a financial transaction with the CBSA on their own account. With the implementation of CARM, the statement of account will no longer be transaction-based and will instead be account-based to provide a summary of all transactions recorded in the billing period.

The SOA will be issued at either the Program Account (BN15) or legal entity/Business Account (BN9) levels, depending on the offsetting option.

  • Program account offsetting: One statement of account per BN15 (one per program account). Credits within a program account can only offset debits on the same program account.
  • Program type/intra-program offsetting: One statement of account per program type (i.e., can group many BN15s).
  • Legal entity/inter-program offsetting: One statement of account per BN9 (one per legal entity).

Q: How will financial security work with CBSA CARM?

Security may be posted in the form of a cash bond, a (continual) surety bond, or a one-time single-entry bond. Without RPP security, you will be required to pay in advance on the CARM Client Portal.

The posted financial security will secure all accounts payable, including duties and taxes (GST), as well as interest, adjustments, ascertained forfeitures, and SIMA fees. The bond will secure any penalty fees.

The amount of the security required for non-cash bonds must be equal to or greater than 50% of the importer’s highest monthly accounts payable to the CBSA within the most recent 12-month period. The bond amount is also subject to a $25K minimum and $10M maximum.

Release Prior to Payment (RPP) financial security will be set at the importer level as of CARM Release 2.

CBSA Assessment and Revenue Management | C.H. Robinson (2024)


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